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FAA: Winging it with Arbitrary Numbers & Declarations

In a recent cartoon, the concerns of residents in the Santa Cruz Mountains area (south of the San Francisco Airport) were graphically presented by Steven DeCinzo:DeCinzo’s Op/Ed is drawing many chuckles. But, more importantly, it is not an exaggeration of how upset people are by the changes FAA has imposed. All under the guise of ‘NextGen’, in a contemporary example of aviation ‘greenwashing’.

So, why are people so upset?

Well, there is clearly the lost quality of life (sleep interruption at night, and new streams of aviation noise during many stretches of the day). But, the upset is compounded by how FAA came to impose these procedures. There was the CATEX rule (categorical exclusions), manipulated through Congress in late 2011, as a workaround that would eliminate FAA’s need to do full environmental reviews. And, there was the broad use of FONSI declarations, also as a workaround to eliminate any real environmental review.

FONSI means Finding of No Significant Impact. In July 2014, FAA declared FONSI on their NorCal OAPM (for Northern California), thus declaring their belief that nobody would be bothered by the proposed new NextGen arrival and departure procedures. Boy, were they wrong. But this is not surprising. Fact is, FAA routinely says what they need to say (not what the facts would have them say) to check off the boxes, to complete the required processes, to go forward with their plans. And, also routinely, their ‘plans’ are not to serve the airport neighbors, but to bring ‘relief’ to the airlines, so that they are no longer burdened by pesky environmental restrictions.

Oh, and FAA is repeating the NorCal OAPM process in Southern California right now; they have published hundreds of pages of SoCal OAPM documents and plan to announce yet another FONSI in the coming months.

An Example of FAA’s Arbitrary Numbers

The NorCal OAPM paper was done by ATAC, and followed an analysis done by SH&E, in 2009, Baseline Capacity & Delay Analysis for the Primary Bay Area Airports. Here is a JPEG showing page 9 from the SH&E study:

The figures reflect actual airport operations (takeoffs and landings) for 2007, and projections for 2020 and 2035. Dark blue shows a projected slow increase in the number of passenger airline operations. Light green is air cargo. Medium blue is general aviation (GA). And, pale blue are GA ops that stay in the local pattern (mostly for flight instruction). An orange line has been added on the left side, identifying the annual itinerant operations totals at around 255,000, but projected to exceed 300,000 by 2035. The prediction was to stay flat, but instead, at the midpoint toward 2020, there has been a sharp decline to average just 170,000 operations in the past two years.

What’s shocking is that FAA pays money for these projections and uses them to justify new programs like NextGen. All while not looking at the real data. So, here is the real data, copied from FAA’s ATADS site (and with peak years highlighted):What the real data shows is that operations at Oakland peaked nearly twenty years ago, in the mid-1990’s. By the time the SH&E study was done, they had declined by a third, so the study projected a brief flattening and a rebound by 2035. Well, instead of a brief flattening we have seen a massive decline, and the 2014 total itinerant operations are now a 57% decline from peak year 1997. The steady downward trend shows no sign of reversing.

How does this connect back to NextGen?

When trying to justify NextGen, FAA routinely implies (and in some situations outright states) that NextGen is critically needed to increase capacity, to prepare for future demand. At airports across the nation, such as at SFO, established routes are being abruptly abandoned in favor of imposed NextGen routes. Despite the fact that these established routes had evolved slowly, sometimes over decades, to balance aviation efficiency against airport neighbor quality of life, FAA is proceeding with their wholesale abandonment.

These abandonment actions are being done as part of the NextGen implementation, and they are all predicated on the FAA belief that they are necessary, to accommodate future growth. The Oakland example shows that FAA has no real data to back that up. And, this is the case not just at Oakland, but also at the vast majority of the primary U.S. commercial airports.

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